Privacy Policy
Effective as of October 2, 2023.
This Privacy Policy describes how GV Management Company, L.L.C. and GV UK Management Company
Limited (collectively, "GV," "we," "us," or "our") handles personal information that we collect throughour website at https://www.gv.com/ and any other digital properties or locations that links to this Privacy
Policy (collectively, the “Service”), as well as through other activities described in this Privacy Policy.
California residents: See our Notice to California residents for information about your personal
information and privacy rights.
Individuals in the European Economic Area (“EEA”)/United Kingdom (“UK”): See our EEA/UK notice for
information about your personal information and data protection rights.

Index
●

Personal information we collect●

How we use your personal information●

How we share your personal information●

Your choices●

Other sites and services●

Security●

International data transfers●

Children●Changes to this Privacy Policy●

How to contact us●

Notice to California residents●

EEA/UK notice

Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service orotherwise includes:●

Contact data. Your first and last name, email address, mailing addresses, professional title andcompany name, phone number and other contact details.

●

Company data. Any information about you, your colleagues, or your company that you share with
us in relation to investments or potential investments in your company by the funds we manage,
such as your and colleagues’ professional and educational backgrounds.

●

Communications data. Information in your communications with us, including when you contact
us through the Service, social media, events, or otherwise.

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●

Event registration data. Information you provide when you register for or attend in-person or
online events that we host or co-host.

●Job candidacy data. Information about your candidacy for a job at one of our portfolio companies,
such as your professional and educational background.

●

Other data not specifically listed here, which we will use as described in this Privacy Policy or asotherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal
information we obtain from other sources, such as:●

Business contacts who send us information about entrepreneurs or candidates for jobs with ourportfolio companies.

●

Publicly available sources, such as social media platforms and other publicly available sources.

Automatic data collection. We and our service providers may automatically log information about you,your computer or mobile device, and your interaction over time with the Service, our communications,and other online services, such as:●

Device data, such as your computer or mobile device’s operating system type and version,
manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device
type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising
purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE,
3G), and general location information such as city, state or geographic area.

●

Online activity data, such as pages you viewed, how long you spent on a page, the website you
visited before browsing to the Service, navigation paths between pages, information about youractivity on a page or screen, access times and duration of access, and whether you have opened
our emails or clicked links within them.

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more
information, see our Cookie Notice. We will also store a record of your preferences in respect of the useof these technologies in connection with the Service.

How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the timeof collection:
Service delivery and business operations. We may use your personal information to:●provide, operate and improve the Service and our business, including to explore new investment
opportunities, manage our existing portfolio, and develop and maintain our contacts and recruit
staff;●

explore business opportunities, conduct due diligence and execute transactions, including ourinvestments in companies and investments in the funds we manage;●

promote and host events;●

help our portfolio companies explore business opportunities and recruit and evaluate job
candidates;●

provide support for the Service, and respond to your requests, questions, and feedback; and2●communicate with you about any of the above or other matters.

Marketing. We, our service providers may collect and use your personal information to send you direct
marketing communications. You may opt-out of our marketing communications as described in the Optout of marketing section below.
Compliance and protection. We may use your personal information to:●comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas
or requests from government authorities;●

protect our, your or others’ rights, privacy, safety or property (including by making and defending
legal claims);●

audit our internal processes for compliance with legal and contractual requirements or ourinternal policies;●

enforce the terms and conditions that govern the Service; and●prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal
activity, including cyberattacks and identity theft.

How we share your personal information
We may share your personal information with the following parties and as otherwise described in thisPrivacy Policy or at the time of collection.
Service providers. Third parties that provide services on our behalf or help us operate the Service or ourbusiness (such as hosting, information technology, customer support, and email delivery).
Portfolio companies. We may share personal information about job candidates and other businesscontacts with portfolio companies with whom we are collaborating to assist those companies with theirbusiness and recruiting activities.
Investors. We may share personal information with investors and prospective investors in our funds biosand other information about the founders and key personnel of our portfolio companies.
Event co-sponsors and marketing partners. We may share personal information with third parties withwhom we co-sponsor events and marketing partners.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where
necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe ingood faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiationsof or due diligence for such transactions) involving a corporate divestiture, merger, consolidation,acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or
equity interests in, GV (including, in connection with a bankruptcy or similar proceedings).

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Your choices
In this section, we describe the rights and choices available to all users. Users who are located in California,
the UK and the EEA can find additional information about their rights below.
Opt-out of marketing communications. You may opt-out of promotional emails by following the opt-out
or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose
to opt-out of promotional emails, you may continue to receive service-related and other non-marketing
emails.
Cookies. For information about cookies employed by the Service and how to control them, see our Cookie
Notice.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online
services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do
Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If
you do not provide the information we identify as required or mandatory, we may not be able to provide
those services.

Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third
parties. In addition, our content may be integrated into web pages or other online services that are notassociated with us. These links and integrations are not an endorsement of, or representation that we areaffiliated with, any third party. We do not control websites, mobile applications or online services
operated by third parties, and we are not responsible for their actions. We encourage you to read theprivacy policies of the other websites, mobile applications, and online services you use.

Security
We employ technical, organizational and physical safeguards designed to protect the personal
information we collect. However, security risk is inherent in all internet and information technologies, andwe cannot guarantee the security of your personal information.

International data transfer
We have offices in the United States and the UK and may use service providers that operate in othercountries. Your personal information may be transferred to the United States or other locations where
privacy laws may not be as protective as those in your state, province, or country.
Users in the UK and the EEA should read the important information provided below about the transfer of
personal information outside of the European Union (“EU”).
As described in our Data Privacy Framework certification, we comply with the EU-U.S. Data Privacy
Framework Principles and the UK Extension to the EU-U.S. Data Privacy Framework Principles and SwissU.S. Data Privacy Framework Principles (collectively, the “Data Privacy Frameworks”) as set forth by the
U.S. Department of Commerce. GV has certified to the U.S. Department of Commerce that GV adheres tothe applicable Data Privacy Frameworks with regard to the processing of personal data received from theEU, UK and Switzerland, respectively to the United States. If there is any conflict between this privacy
policy and the Data Privacy Frameworks, the Data Privacy Frameworks shall govern. To learn more about
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the
Data
Privacy
Frameworks,
andhttps://www.dataprivacyframework.gov/s/.

to

view

our

certification,pleasevisit:

Although GV has certified to the Data Privacy Frameworks, GV does not rely on the Data Privacy
Frameworks as a legal basis for transfers of personal information from the EU to third countries in light of
the recent decisions by the Court of Justice of the EU and the Swiss Federal Data Protection andInformation Commissioner (“FDPIC”). GV utilizes legally recognized mechanisms to facilitate the transferof personal information from the EU and Switzerland to the United States and other third countries.
In the event of an onward transfer of personal information received in reliance on our Data Privacy
Framework certification, GV remains responsible for any of your personal information that is shared under
the Onwards Transfer Principle with third parties for external processing on GV's behalf, as describedabove.
In compliance with the Data Privacy Frameworks, GV commits to resolve Data Privacy Frameworks-related
complaints about our collection and use of your personal information. EU, UK and Swiss individuals withinquiries or complaints regarding our handling of personal data received in reliance on the Data Privacy
Frameworks should first contact GV at: privacy@gv.com.
In compliance with the Data Privacy Frameworks, GV commits to refer unresolved complaints concerning
our handling of personal data received in reliance on the Data Privacy Frameworks to the following
alternative dispute resolution providers, as applicable: the applicable EU data protection authority("DPA") in the EU, the UK Information Commissioner's Office (“ICO”) in the UK, the FDPIC in Switzerland,or alternatively, to JAMS at https://www.jamsadr.com/eu-us-data-privacy-framework. If you do notreceive timely acknowledgment of your Data Privacy Frameworks-related complaint from us, or if we havenot addressed your Data Privacy Frameworks-related complaint to your satisfaction, please visit thewebsite of the applicable alternative dispute resolution provider linked above for more information or to
file a complaint. The services of such alternative dispute resolution provider are provided at no cost to
you and we commit to comply with the advice given by the applicable alternative dispute resolution
provider.
In certain circumstances, the Data Privacy Framework provides the right to invoke binding arbitration toresolve complaints not resolved by other means, as described in Annex I to the Data Privacy Framework
Principles. In such circumstances, GV is obligated to arbitrate such claims and follow the terms as set forthin Annex I of the Data Privacy Framework Principles.

Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy
Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or otherappropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified
version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after theeffective date of any modified Privacy Policy indicates your acknowledgment that the modified Privacy
Policy applies to your interactions with the Service and our business.

5How to contact us
If you have questions or concerns about this Privacy Policy or our practices, please contact us at:
GV Management Company, L.L.C.
1600 Amphitheatre Pkwy,
Mountain View, CA 94043
privacy@gv.com

Notice to California residents
This notice describes our collection, use and disclosure of personal information of California residents in
our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights withrespect to their personal information. For purposes of this notice, “personal information” has the meaning
given in the CCPA but does not include information exempted from the scope of the CCPA.
Your privacy rights. As a California resident, you have the following rights under the CCPA:●

Right to know. You can request information about the categories of personal information that wehave collected; the categories of sources from which we collected personal information; thebusiness or commercial purpose for collecting, sharing and/or selling personal information; thecategories of any personal information that we sold or disclosed for a business purpose; and thecategories of any third parties with whom personal information was sold, shared or disclosed fora business purpose.

●

Right to access. You can request a copy of certain personal information that we have collected
about you.

●

Right to deletion. You can request that we delete personal information that we collected fromyou.

●

Right to correction. You can request that we correct inaccurate personal information that wehave collected about you.

●

Nondiscrimination. You are entitled to exercise the rights described above free fromdiscrimination as prohibited by the CCPA.

Identity verification. You may submit requests to exercise your right to know, access, deletion andcorrection to privacy@gv.com. The rights described above are not absolute, and in certain cases, we may
decline your request as permitted by law. We cannot process your request if you do not provide us with
sufficient detail to allow us to understand and respond to it.
Information practices. The following describes our practices currently and during the past 12 months:●

Sources and purposes. We collect all categories of personal information from the sources and use
them for the business/commercial purposes described above in the Privacy Policy.

●

Sales and sharing of personal information. We do not “sell” or “share” personal information as
those terms are defined in the CCPA and have no actual knowledge that we have sold or shared
the personal information of California residents under 16 years of age.

●

Sensitive personal information. We do not use or disclose sensitive personal information for
purposes that California residents have a right to limit under the CCPA.

6●

Retention. The criteria for deciding how long to retain personal information is generally based onwhether such period is sufficient to fulfill the purposes for which we collected it as described inthis notice, including complying with our legal obligations.

●Collection and disclosure. The chart below describes the personal information we collect byreference to the categories of personal information specified in the CCPA (Cal. Civ. Code
§1798.140), and the categories of third parties to whom we disclose it. The terms in the chartrefer to the categories of information and third parties described above in this Privacy Policy inmore detail. Information you voluntarily provide to us, such as in free-form webforms, may
contain other categories of personal information not described below. We may also disclose
personal information to professional advisors, law enforcement and government authorities, andbusiness transferees as described above in the “How we share your personal information” sectionof this Privacy Policy.
Statutory category/personal information
we collectCategories of third parties to whom we disclose thepersonal information for a business purpose

Identifiers● Contact data
● Company data
● Job candidacy data
● Event registration data

● Service providers● Portfolio companies● Investors

Identifiers (online)● Device data

● Service providers

California Customer Records (as defined in
California Civil Code §1798.80)● Contact data
● Company data
● Job candidacy data
● Event registration data
● Communications data●
Commercial Information● Contact data
● Company data
● Job candidacy data
● Event registration data
● Online activity data

● Service providers● Portfolio companies● Investors

Internet or Network Information● Device data
● Online activity data

● Service providers

Professional or Employment Information● Company data
● Job candidacy data

● Service providers● Portfolio companies

Education Information● Company data
● Job candidacy data

● Service providers● Portfolio companies● Service providers● Portfolio companies● Investors

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Inferences
May be derived from:● Contact data
● Company data
● Event registration data
● Online activity data

● Service providers● Portfolio companies● Investors

Protected Classification Characteristics
May be included or revealed in:● Contact data
● Company data
● Job candidacy data

● Service providers● Portfolio companies● Investors

EEA/UK notice
Our legal basis for processing your personal information
If UK data protection law applies to our processing of your personal information, it is important that you
know the lawful basis on which we process your personal information.
We rely on the following legal basis, under UK data protection law, to process your personal information:●

Where we have obtained your consent, for example to action a request from you or respond to
your specific query. You can withdraw your consent at any time, but we may still need to retain arecord of your correspondence with us.

●

Where it is necessary for the purposes of our legitimate interests to manage our existing
investments and explore new investment opportunities, including conducting legal andcommercial due diligence.

●

Where it is necessary to comply with a legal obligation, for example under anti-money launderingor anti-bribery legislation.

Enforcement
GV is subject to the investigatory and enforcement powers of the US Federal Trade Commission. We may
be required to share your personal information, including the disclosure of EU and Swiss personal
information, to public authorities and law enforcement agencies in response to lawful requests, including
requests to meet national security and law enforcement requirements.

Right to access, update and delete your personal information
If you are a resident of the UK or the EU, you have certain legal rights in respect of the personal
information about you held by us. This includes the right to obtain a copy of this information on request,
and the right to correct, amend or delete such personal information or object to it being used for certain
purposes (including marketing). We may ask you to verify your identity before we can act on your request.
We will comply with any requests to exercise your rights in accordance with applicable law, and so there
may be circumstances where we are entitled to refuse your request. For example, where permitted toby law, we may reject requests that are unreasonably repetitive, require disproportionate technicaleffort (for example, developing a new system or fundamentally changing an existing practice), risk theprivacy of others, or would be extremely impractical (for instance, requests concerning information
residing on backup systems).
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Where we can provide information access and correction, we will do so free of charge, except where it
would require a disproportionate effort (where we are permitted to charge a fee under applicable law).
We aim to maintain any information we hold and our Site in a manner that protects information from
accidental or malicious destruction.
To make any requests regarding your personal information, or if you have any questions or concerns
regarding your personal information, you should contact us at privacy@gv.com. You are also entitled tocontact your local supervisory authority for data protection. In the UK, the data protection authority is
the Information Commissioner’s Office.

Right to object
You have the right to object (opt-out) of your personal information being used for purposes which arematerially different to the purposes for which it was collected, as described in this Privacy Policy (including
being disclosed to a third party). We may refuse your request where we have a right to do so (for example,
if the use is necessary to comply with a legal obligation). To exercise any of your rights, please contact us
at privacy@gv.com.

Contacting us
Please submit any questions, concerns or comments you have about this Privacy Policy or any requests
concerning your personal information by email to privacy@gv.com.
For the purposes of UK data protection law, GV UK Management Limited is the data controller of yourpersonal information. Our address in the UK is 146-148 Clerkenwell Road, London, EC1R 5DG.

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Cookie NoticeThis Cookie Notice explains how GV Management Company, L.L.C. and GV UK Management Company
Limited (collectively, "GV," "we", "us," or "our") uses cookies and similar technologies in connection withthe https://www.gv.com/ website and any other website that we own or control and which posts or links
to this Cookie Notice (collectively, the “Sites”).
What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website.
Cookies serve different purposes, like helping us understand how a site is being used, letting you navigate
between pages efficiently, remembering your preferences, and generally improving your browsing
experience.
Our Sites may use both session cookies (which expire once you close your web browser) and persistentcookies (which stay on your computer or mobile device until you delete them).
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer ormobile device, which we use to recognize your computer or mobile device when it revisits our Sites; and(2) third-party cookies, which are served by service providers or business partners on our Sites, and canbe used by these parties to recognize your computer or mobile device when it visits other websites. Thirdparty cookies can be used for a variety of purposes, including site analytics.
What types of cookies and similar tracking technologies do we use on the Sites?
On the Sites, we use cookies and other tracking technologies in the following categories described in thetable below.
Type

Description

Who serves the cookies(link to privacy policy/site)

Advertising

These cookies are used by None.
advertising companies tocollect information about
how you use our Sites andother websites over time.
These companies use thisinformation to show you
ads they believe will be
relevant to you within ourservices and elsewhere,
and to measure how theads perform.

N/A

Analytics

These cookies help us Google Analytics
understandhow
ourservices is performing andbeing used. These cookies
may work with web
beacons included in emails
we send to track which
emails are opened andwhich links are clicked by

You can find out more
information about Google
Analytics cookies here and
about
how
Googleprotects your data here.
You can prevent the use of
Google Analytics relating
to your use of our Sites bydownloading
and10

How to control them

Type

Description

Who serves the cookies(link to privacy policy/site)

How to control them

installing a browser plugin
available here.

recipients.

See ‘your choices’ below.

Essential

Functionality
performance

SocialThese
cookiesare None.
necessary to allow thetechnical operation of ourservices (e.g., they enable
you to move around on a
website and to use its
features).

N/A/ Enhance the performance None.
and functionality of ourservices.

N/A

These cookies may allow None.
you to log into the Sites or
App through your social
media account or sharecontent in our sites thatyoufindinteresting
through third-party social
media providers. These
cookies may also be used
for advertising purposes.

N/AYour choices
Your options for controlling what information cookies and similar technologies collect about you include:●

Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this,follow the instructions in your browser settings. Many browsers accept cookies by default until
you change your settings. Please note that if you set your browser to disable cookies, the Sites
may not work properly. For more information about cookies, including how to see what cookies
have been set on your device and how to manage and delete them, visit
www.allaboutcookies.org. If you do not accept our cookies, you may experience someinconvenience in your use of our Sites. For example, we may not be able to recognize yourcomputer or mobile device and you may need to log in every time you visit our Sites.

●

Blocking images/clear gifs: Most browsers and devices allow you to configure your device toprevent images from loading. To do this, follow the instructions in your particular browser or
device settings.

For more information about cookies, including how to see what cookies have been set on your computeror mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept
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our cookies, you may experience some inconvenience in your use of our Sites. For example, we may not
be able to recognize your computer or mobile device and you may need to log in every time you visit ourSites.
For more information about how we collect, use and share your information, see our Privacy Policy.
Changes
Information about the cookies we use may be updated from time to time, so please check back on aregular basis for any changes.
QuestionsIf you have any questions about this Cookie Notice, please contact us by email at privacy@gv.com.
Last modified December 2, 2022.

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